Customer Compliant Notice – SEC Rule 17a-3(a)(18)(ii) Disclosure Statement

InvestX Markets LLC in accordance with Rule 17a-3(a)(18)(ii), is furnishing this statement to provide you with a name, telephone number and address, if you ever need to report or notify us of a possible complaint. If, for any reason, you feel you have a complaint, please contact our offices immediately, either by mail at InvestX Markets LLC 1111 Melville Street, Suite 510, Vancouver, BC V6E 3V6, Canada Attention: Compliance Department or (778) 588-7148 and ask to speak with our Compliance Officer.

SIPC and FINRA Notification

SIPC Notification

InvestX Markets LLC is a member of the Securities Investor Protection Corporation (SIPC), which protects securities of its members up to $500,000 (including $250,000 for claims for cash). However, we do not hold customer funds and securities. Funds and securities held by outside institutions are not covered by our SIPC protection.

All customers are advised that information about SIPC, including the SIPC brochure, may be obtained by contacting SIPC. SIPC may be contacted by phone, email or regular mail:

For more detailed information please visit the SIPC website at www.sipc.org

FINRA Notification

FINRA’s public disclosure program toll free hotline number is 1(800)289-9999 and FINRA’s website address is: http://www.finra.org

InvestX Financial (Canada) Ltd. Privacy Policy

Last updated: March 26, 2025

Introduction

InvestX Financial (Canada) Ltd. and its affiliates (“InvestX”, “we”, “us”, “our”) take the protection of your privacy seriously. This privacy policy (the “Privacy Policy”) applies to you if you access our website or online portal located at www.investx.com (the “Website”), use our products and services, or engage with us in other ways (collectively, the “Services”). In this Privacy Policy, we explain how we collect, use, disclose, and retain your personal information in the course of conducting our business.

This Privacy Policy will continue to apply for as long as InvestX holds your information, including after the termination of any of your product or service agreements with us. By providing your information to us, you are consenting to the collection, use or sharing of your information as set out in this Privacy Policy and as otherwise permitted by applicable law.

“Personal information” or “information” is broadly defined and means any information that can be used, either alone or in combination with other information, to identify an individual. This can include information such as your name, mailing address, email address, telephone number, financial information, account numbers, or any other identifiable information. It may also include other types of more technical information, but only when this information can identify you as an individual, such as your IP address, the device you use to access the Website and details about your usage of the Website. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be personal information.

Your Consent

We require your expess or implied consent to collect, use, disclose or retain your personal information. In certain situations, you may provide your consent through an authorized representative such as a lawyer, agent, or broker. Express consent may be given orally, in writing, or electronically. Implied consent is obtained when InvestX can reasonably infer consent based on your circumstances. Subject to legal, business or contractual requirements, you have a right to withdraw or refuse your consent at any time, provided you give us reasonable notice. However, this withdrawal or refusal may limit the Services that we provide you. If this information is required by law, we may decline or discontinue our relationship with you.

There are a limited number of situations where InvestX is legally permitted or required to disclose your personal information without your consent, as outlined in applicable privacy legislation.

Collecting Your Personal Information

Information you provide directly to us

In many cases, we may collect personal information directly from you when you are interacting with us, including when completing new account application forms and related documentation, and during your use of our Services or the Website.

For example, we may collect:

• contact information (such as name, email address, postal address and phone numbers) when you make a general inquiry, including when you contact us through the Website;
• contact information (such as name, email address, phone numbers and mailing address), social insurance number and other government-issued identification information, demographic information (such as date of birth, age, employment information, family information, citizenship, whether you are a tax citizen of other countries and whether you are a politically exposed person and other personal circumstances), banking information and information about your financial circumstances (including net worth, income, tax status, liabilities and assets held with other firms), investment knowledge, objectives and strategies when you contact us as a prospective client or register for or use our Services as a client;
• contact information, and employment information when you apply for an employment opportunity with InvestX; and
• contact information, communications preferences and correspondence you send to us.

In these cases, you can choose to withhold certain requested personal information; however, this may limit your ability to access or use certain features of the Website or otherwise receive the full benefit of InvestX’s Services.

If you provide us with the personal information of another individual, you are fully responsible for complying with all applicable laws, including obtaining the individual’s valid consent, regarding your collection and disclosure of the personal information to InvestX, and to InvestX’s use, disclosure and retention of the information.

Information collected automatically

In some cases, we may collect information automatically regarding your use of the Website, such as the dates and times that you access the Website, the browsers, operating systems, software, devices and networks that you use to access the Website; and other details of your use of the Website.

The Website, email communications, and advertisements may also use technologies such as cookies, web beacons, tokens, pixels or tags to automatically collect information. This helps us improve our products, services, client interactions, advertising, and prevent fraud.

Some of the information automatically collected is non-personal information (because the information does not identify you), and we will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

Information from other sources

In some other cases, we may collect personal information from third parties, including financial institutions, government agencies, regulatory institutions, referrals you have provided, and publicly available sources. We will only do so with your consent or as permitted or required by applicable law.

Using Your Personal Information

General

InvestX may use your personal information for various purposes in connection with our relationship and transactions with you and as otherwise set out in this Privacy Policy or permitted by applicable law, including:

• to provide Services to you;
• to facilitate your interactions and transactions with InvestX;
• to transfer your account to or from another institution;
• to meet InvestX’s legal and regulatory requirements;
• to contact and correspond with you and others that you may designate as your representatives from time to time;
• to process and respond to your inquiries, requests and other communications;
• to provide you with information (including by email and other electronic messages) regarding InvestX and its Services, to the extent permitted by applicable law;
• to maintain, protect and improve InvestX’s Services and Website;
• to develop, deliver and improve InvestX’s advertising and marketing;
• in accordance with express consents that you give during your interactions and transactions with InvestX;
• to protect and enforce InvestX’s legal rights, interests and remedies and to protect the business, operations and clients of InvestX or other persons; and
• if you have applied for an employment position with InvestX, we will use your personal information to administer and process your application for employment and other customary human resources purposes.

We may combine your personal information collected by InvestX through various sources.

InvestX may use your personal information to create non-personal information, and InvestX may then use, disclose, transfer and retain the non-personal information as set out below in this Privacy Policy.

Cookies and tracking technology

InvestX may use cookies and similar tracking technologies on the Website to enhance your user experience, analyze Website traffic, and improve our service offerings. This information is used solely by InvestX for Website functionality, analytics, and security purposes, and we do not share or sell this information.

You can block the use of cookies by activating the settings in your browser. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to withhold consent, or subsequently block cookies, you may not be able to access all or part of the content of the Website.

Disclosing Your Personal Information

General

InvestX may disclose your personal information for purposes relating to or arising from your relationship and transactions with InvestX and as otherwise set out in this Privacy Policy or permitted by applicable law. We do not sell your personal information to third parties.

Specific consents

InvestX may disclose your personal information in accordance with express or implied consent that you give during your interactions and transactions with InvestX.

Service providers

InvestX may disclose your personal information to its service providers to assist InvestX in the provision of Services to you, to provide services to InvestX, to assist InvestX to use your personal information as set out in this Privacy Policy, and as otherwise permitted by applicable law. When personal information is provided to our service providers, we will require them to protect the information in a manner that is consistent with our privacy and security policies, practices and standards.

Disclosures in connection with your Services

We may disclose your personal information in connection with the Services we provide to you. For example,

1. If a Service involves shared ownership or liability, we may disclose your information with such other persons in connection with the Service.
2. In the event of your passing, we may share your information with your beneficiaries or estate representatives, as necessary, to help in the administration of your estate’s financial affairs.
3. If you are the surviving joint account-holder, we may disclose information about your account or information collected before a deceased joint account-holder’s death with the representative of the deceased joint account-holder.
4. Where someone is acting as your representative, or we reasonably believe they are authorized to do so, such as a legal guardian, person having power of attorney, estate representative, lawyer, and accountant, we may share your information with and take instructions from them, including sharing information as instructed by either representative where representatives are jointly appointed.

Business partners and other third parties

In certain circumstances, we may share personal inormation with our business partners, such as strategic business partners who provide products and services that enhance your experience with us, and other third parties. For example, we may disclose your information to your accountant or financial planner on your request. We will only disclose your personal information to a third party if we have your consent to do so, if you have provided your consent to the third party, or if we are legally required or permitted to do so.

As permitted or required by law

InvestX may disclose your personal information as required or authorized by applicable law, including to comply with a law, regulation, court order, subpoena, valid demand, search warrant, government investigation, other legally valid requests or enquiries or to otherwise meet our compliance, regulatory and financial crime risk management obligations. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.

We reserve the right to disclose your personal information to law enforcement agencies or other independent organizations if we reasonably believe the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if we reasonably believe the disclosure is necessary or appropriate to protect and enforce InvestX’s legal rights, interests and remedies or to protect the rights, interests, business, operations or clients of InvestX or other persons (including to detect and prevent fraud and other illegal activities, to enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of InvestX’s Services). InvestX has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the agencies, independent organizations or other persons to whom InvestX discloses the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.

Business transaction

We may disclose your persona information to a third party in connection with a proposed or actual business transaction in which InvestX is involved (for example, an amalgamation, a re-organization, a financing of parts of our business, or the sale or transfer of some or all of InvestX’s business or assets), but InvestX will require the information recipient to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

Your Right to Withdraw Consent

You may withdraw your consent to InvestX’s collection, use, disclosure and retention of your personal information as set out in this Privacy Policy at any time by giving us reasonable notice, subject to legal and regulatory or contractual restrictions. If you wish to withdraw consent, you may do so by contacting us at the contact information set out at the end of this Privacy Policy.

If you withdraw your consent for purposes that are integral to the provision of InvestX’s Services, then you might not be able to proceed with your intended interactions or transactions with InvestX or otherwise receive the full benefit of InvestX’s Services.

If you withdraw your consent for additional purposes that are not integral to the provision of InvestX’s Services (e.g., to send advertising and marketing messages to you and to conduct surveys) then withdrawing your consent for those purposes will not impact the provision of InvestX’s Services to you.

Accuracy and Safeguarding

InvestX will rely on you to ensure that the personal information that you provide us is accurate, complete, and up-to-date as necessary for the purpose for which InvestX uses the personal information. You will promptly notify us of any changes to the personal information that you provide to InvestX using the procedures made available for that purpose by InvestX or by contacting us using the contact information noted at the end of this Privacy Policy. Keeping your information accurate and current lowers your fraud risk, ensures accurate reporting on our part and allows us to continue to offer you the highest-quality service.

InvestX uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in InvestX’s possession or under InvestX’s control to help protect the information from unauthorized use, sharing, loss, theft or similar risks. We regularly audit and assess our security measures to ensure that they are effective and appropriate. Access to sensitive systems, physical or digital, is secured and limited to qualified persons only. However, no method of data transmission over the Internet can be fully guaranteed to be completely secure. Accordingly, we cannot fully guarantee the security of any information that you transmit to us, so you do so at your own risk.

Accessing Your Personal Information

You can request to access or update your personal information held by InvestX. To do so, simply submit a written request using the contact information provided at the end of this Privacy Policy. You may request access to your personal information collected by InvestX, as well as details about how your information is used, disclosed, and retained.

To process your request, we may ask you for information to validate your identity and confirm the scope of your request, such as the relevant time period or a specific description of the information you are seeking access to. Subject to applicable exceptions and limitations prescribed by applicable law, we will provide you with reasonable access to your personal information. You will also have the right to verify its accuracy, completeness, and request corrections as needed.

You may be required to pay a reasonable fee for access to your personal information. We will advise you of the fee, if any, prior to proceeding with your request.

We will provide the information in a format that is accessible to you. If we obtained your information from others, you can ask us for the source of that information. On request and where legally permitted, we will provide you with the names of the third parties to whom we have given or may have given your information. However, this excludes service providers we have used to do work for us. It will also not include reports to the Canada Revenue Agency or information that has been provided for legal and regulatory obligations.

We may not be able to provide you with access to your personal information in certain circumstances, such as where your request includes personal information about a third party that cannot be removed, or when the information you are requesting is protected by legal privilege.

Data Storage and Retention

InvestX retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, as well as for client service, legal and reasonable business purposes, which may extend beyond the end of your relationship with us. The duration of retention depends on the type of information and the Services provided. Once your personal information is no longer needed, it will be securely destroyed or deleted. Your information may be stored in InvestX’s office, in various computer systems, or within the record storage facilities managed by InvestX or our service providers.

Location of Personal Information

Your personal information may be processed, stored, and used in countries where we, our affiliates, or service providers operate, including Canada, the United States, and other countries. The personal information protection laws of those other countries may differ from the laws of the jurisdiction in which you reside, and might permit those countries’ governments, courts, or law enforcement agencies to access your personal information.

By using our Services, you consent to the transfer, processing, and storage of information to countries outside of Canada. When your information is transferred to and stored in locations outside of Canada, we will ensure it has an appropriate level of protection and that the transfer is lawful.

CASL Policy

We are committed tocomplying with Canada’s Anti-Spam Legislation (“CASL”). CASL governs, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send, subject to certain exceptions and exclusions. For more information on CEMs, please refer to CASL or guidance published by the Canadian Radio-television and Telecommunications Commission.

As part of our commitment to compliance with CASL, we have implemented the following measures:

1. Consent – We obtain consent prior to sending you a CEM. We may collect your “express” consent (expressly acknowledged by you), but in certain circumstances your consent may be “implied” or specifically exempt from consent requirements. We ensure that our consent collection process is meaningful to you (i.e. informed and freely given), in accordance with CASL. When we collect your electronic contact information, we will communicate the purpose behind the collection.
2. Content – Under CASL, we ensure that the following elements exist before we send a CEM. We will:
   • Identify ourselves as the sender of the CEM;
   • Provide our contact information (i.e. mailing address and one of the following: (a) telephone number; (b) email address; or (c) web address); and
   • Include a valid unsubscribe mechanism.

In accordance with CASL, we will process unsubscribe requests within 10 business days. If you have any questions or concerns regarding our unsubscribe process, you may contact us using the contact information set out at the end of this Privacy Policy.

Non-Personal Information

We may use your personal informtion to create and collect non-personal information (information that is not about an identifiable individual), including information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. We may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever, subject to applicable laws. If non-personal information is combined with personal information, then we will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with the personal information.

Links to Other Websites

This Privacy Policy applies only to the Services provided by InvestX. Our Services may include links to other websites and services not operated by us (the “Third Party Sites”). These Third Party Sites are governed by their own privacy statements, and we have no responsibility or liability for, or control over, their information practices. If you have questions about how those Third Party Sites collect, use, disclose or retain personal information, please contact the owner or operator of the Third Party Site. Furthermore, we do not control and are not responsible for any content on the Third Party Sites.

Children’s Data

We do not knowingly collect personal information from children under 13 years of age without proper consent from a parent or legal guardian. If you believe we might have collected information from or about a child where parental or legal guardian consent was required, please contact us using the contact information set out at the end of this Privacy Policy and we will investigate the issue.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time by updating the Website. Each time you use our Services, the current version of this Privacy Policy will apply.

Contacting Us

If you have questions, concerns, or complaints regarding your privacy or this Privacy Policy, please contact us at: